The NPPF states that the Government’s objective is to significantly boost the supply of homes. The GNLP addresses this through the housing strategy in policies 1 and 7 and the housing allocations in the Sites document.
The NPPF also states that major housing developments should meet the need for affordable housing on-site, with at least 10% of the affordable homes available for affordable home ownership. The NPPF puts the emphasis on local plans to identify the amount of affordable housing needed. It also requires local plans to provide a mix of property types and sizes and a variety of affordable housing tenures, as well as meeting the needs of all groups in the community.
To achieve the above and based on local evidence89, the policy encourages the provision of a full range of type, tenure and cost of housing, to meet the varied housing needs of our community. It also included minimum space standards and requirements for adaptable homes to provide an improved quality of life and meet the needs of an ageing population.
The policy is flexible in relation to affordable housing sizes, types and tenures to allow differing needs to be met in the three districts on a site by site basis based on the most up-to-date evidence. Paragraph 43 covers the housing mix requirement based on the most recent housing market assessment. Current evidence shows a higher social rented requirement in the city with a wider range of tenure options suitable in Broadland and South Norfolk. This evidence will be revisited before submission. The policy is pragmatic and adaptable, enabling the most up-to-date evidence on housing need to be used.
- The policy sets a general requirement for on-site affordable housing provision of 33% on sites that show better viability based on local evidence, with a lower requirement in Norwich City Centre. This is based on:
- The Strategic Housing Market Assessment 2017 which identifies a need for 11,030 affordable homes in Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point;
- Under national policy, small sites under 10 dwellings are not required to provide affordable housing. Larger sites will therefore have to ensure that overall affordable housing need is delivered;
- The most recent viability study findings which conclude that centrally located brownfield sites which have higher development costs which affect viability are generally able to provide 28% affordable housing. As national planning guidance makes it clear that where applicants can demonstrate particular circumstances that justify the need for a viability assessment at the planning application stage90, the policy provides some flexibility on this point for brownfield sites where exceptional costs are more likely. In addition, the introduction by the Government of Vacant Building Credit enables existing vacant floorspace on a site to be discounted in order to lower the affordable housing requirement, with aim of incentivising development on brownfield sites;
- Some specific sites have very high costs associated with development. These are allocated with lower affordable housing requirements.
The successful approach of preventing subdivision of sites currently in use in Norwich is applied to the whole area through the policy.
Based on local evidence of need, viability and timing91 and to ensure that new housing provides for a good quality of life, the policy requires housing development across Greater Norwich to meet nationally defined minimum space standards92 for different types of homes.
An increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist Norfolk County Council’s aim to reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing.
The policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing93. Norfolk County Council’s strategy94 identifies the need for 2,842 additional extra care units by 2028. County wide evidence has identified the need for 3,857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 203895.
To help to provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall and site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports delivery of older peoples’ and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up-to-date evidence of need.
The policy includes a local requirement to adhere to the national optional Building Regulation standard for adaptable homes. To achieve this 20% of homes on major developments must be designed to be adaptable to meet changing needs over time, enabling people to stay in their homes for longer
The policy provides for the needs of Gypsies and Travellers. Evidence96 shows planned expansion of the Swanton Road site in Norwich meets Greater Norwich’s need for 15 additional pitches to 2022. A further 51 pitches will be required between 2022 and 2038. The criteria-based policy allows for additional delivery to meet need throughout the plan period and allows for the expansion of well-located existing sites. Since no sites have been submitted for consideration through the local plan, the intention is to bring additional sites forward through the Development Management process as well as having this criteria-based policy to allow further sites to come forward.
The policy also allows for Travelling Show People and Residential Caravan needs to be met through market led solutions through the criteria-based policy. This will allow sites to come forward if there is demand for them. The Broads Authority plans for the needs for residents of houseboats in the area.
The policy also aims to ensure that purpose-built student accommodation is provided to meet growing needs at the UEA and in other locations with good access to the educational facilities they will serve, including Norwich University of the Arts. The policy content and the sites allocated for student accommodation are informed by the UEA Development Framework Strategy97. Purpose-built student accommodation development is required to make provision for affordable housing that would be expected on the specific site if it were to be developed for housing, potentially through a commuted sum. This is required as without doing so, the delivery of sites for student accommodation would reduce the ability to address affordable housing needs.
Local authorities are required to keep a register of those seeking to acquire serviced plots in the area for their own self-build and custom-build housing. In 2018/19, there were 113 people on the registers in Greater Norwich.
In line with the Right to Build and the NPPF, self and custom-build housing delivery is promoted through the GNLP on a range of sites. This policy sets a requirement for larger sites to provide self and custom-build plots. The thresholds have been set to ensure that plots are provided across Greater Norwich. Policies 7.4 and 7.5 also promote self and custom-build on smaller scale windfall sites. Overall, this comprehensive approach will both increase the supply of housing in urban and rural areas and provide opportunities for small and medium enterprises to build houses, as well as for self and custom-build.
Other potential means of helping to provide for local housing needs is through the provision of live-work units and through community led housing initiatives, such as might be provided by a Community Land Trust. Such initiatives will need to be in appropriate locations.
89Local housing evidence is in the Strategic Housing Market Assessment (2017) and in the Greater Norwich Viability Study (2019).
90Planning Practice Guidance – Viability and Decision Taking
91Evidenced through the Greater Norwich Local Plan Nationally Described Space Standards Study (August 2019) within the Viability Study
92The Nationally Described Space Standard is available here
93Extra care housing is a self-contained residential accommodation (where units are rented or owned by the individual or couples who occupy them) with communal facilities designed to meet the needs and aspirations of older people and have care staff on site 24/7.
94Living Well – Homes for Norfolk (2018)
95Three Dragons – Demand for Specialist Older Persons Housing 2020 to 2041 (insert link when available).
96Norfolk Caravans and Houseboats Accommodation Needs Assessment (ANA) including for Gypsies, Travellers and Travelling Show people October 2017
97UEA Development Framework Strategy: Available here